Integrity Policy: Incident Management
Pursuant to legislation, (financial) service providers should have procedures and measures in place for dealing with and recording behavior and events which could pose a serious threat to the integrity of the organization’s business operations.
This includes, among others, the following types of incidents related to integrity:
- Conflicts of interest and disadvantaging third parties;
- Incidents which pose a threat to the institution’s integrity;
- Integrity-related incidents involving persons with an integrity-sensitive function;
- Direct indications of money laundering and terrorist financing;
- Criminal or other legal offenses by the institution or its directors or employees, which could undermine confidence and damage the trust in the institution or the financial sector;
- Incidents related to relationships with consumers, clients or other third parties which could undermine confidence and damage the trust in the institution or the financial sector;
- Other actions by the institution or its employees, which infringe on what is considered to be socially acceptable in such a way that they seriously undermine confidence in the institution or the financial sector.
These behaviors or events are called incidents and must be reported immediately to the supervisory authority.
Compliance Services Caribbean is pleased to assist you in setting up procedures and measures enabling your organization to identify such incidents at an early stage and respond to them accordingly. Based on the results of the internal process it will be determined whether external reporting is also required.
Incidents which pose a serious threat to the integrity of the institutions’ business operations or which could seriously undermine confidence in the institution should be reported. We can assist you in making this assessment and decision.
If an actual incident has occurred, we provide our services from Forensic Services Caribbean to investigate the incident in order to identify the facts and circumstances under which the incident has occurred.
If desired, the investigation can also be used to propose preventive measures. The investigation and possible measures can be used as approach in support of your organization’s mitigation measures when reporting to the supervisory authority.